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Ten organizations, primarily in the steel and cement industries, could share a surplus of €3.2 billion ($4.4 billion) of pollution permits by 2012 under the European Union’s Emissions Trading Scheme (ETS), according to a new report from Sandbag Climate Change and Carbon Market Data. The report (PDF) indicates this is more than double the EU’s investment of €1.5 billion ($2 billion) in renewable energy and clean technology.

The organizations based the estimated surplus on permits sold from 2008 to 2012 at €14 ($19) per permit. The top ten companies expected to benefit from the surplus include ArcelorMittal, Corus, Lafarge, SSAB – Svenskt Stal, Cemex, Salzgitter, U.S. Steel, HeidelbergCement, CEZ, and Slovenské elektrárne.

According to Sandbag, the study’s findings contradict claims by the steel association Eurofer that tougher climate change targets would hurt the industry’s competitiveness.

Another key finding shows that among the key industrial sectors covered by the EU ETS some are over-allocated while others, including some in the iron and steel sector, do not have enough permits to cover their emissions. The study indicates that this could have a significant impact on the implementation of Phase 3 of emissions trading, while raising questions about whether all EU companies are operating on a level playing field. Phase 2 runs from 2008 to 2012.

The study recommends four measures to prevent surplus permits from weakening the scheme’s ability to cut CO2 emissions.

— Set higher targets

— Spur more investment in solutions

— Revisit the design of Phase 3

— Improve the monitoring of the ETS

Here’s a chart of the top 10 companies projected to earn the most from surplus permits.